COUNT 1: FAILURE TO NOTIFY AS A TRANSPORTER/PROCESSOR/ MARKETER OF USED OIL. COUNT 2: FAILURE TO COMPLY WITH STANDARDS FOR USED OIL PROCESSORS/RE-REFINERS, AND MARKETERS. COUNT 3: FAILURE TO COMPLY WITH THE REQUIREMENTS FOR SECONDARY CONTAINMENT FOR CONTAINERS AND TANKS AND RESPONSE TO RELEASES. COUNT 4: FAILURE TO COMPLY WITH THE REQUIREMENTS FOR A CONTINGENCY PLAN AND EMERGENCIES PROCEDURES.